2018 (9) TMI 1237
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....tal Representative for Revenue and the material on record. 2. Briefly stated, the facts relevant for disposal of these appeals are as under :- 2.1 The assessee company is in the business of providing engineering, asset management and maintenance services to hospitals, The order of assessment for Assessment Year 2014-15 was completed under Section 143(3) of the Income Tax Act, 1961 (in short 'the Act') vide order dt.5.8.2016, wherein the following additions / disallowances were made :- i) U/s.14A read with Rule 8D Rs.1,40,10,214 ii) Disallowance of interest expenses Rs.2,42,92,562 2.2 Aggrieved by the aforesaid order of assessment for Assessment Year 2014-15, the assessee filed appeals before the CIT (Appeals) - 4, Bangalore....
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....grounds that may be urged at the time of hearing, it is prayed that the order of the CIT (A) in so far as it relates to the above grounds may be reversed and that of the Assessing Officer may be restored, 5. The appellant craves leave to add, alter, amend and / or delete any of the grounds that may be urged. 4. Grounds 1, 4 & 5, being general in nature, no adjudication is called for thereon. 5. Grounds 2 & 3 - Disallowance under Section 14A r.w. Rule 8D(2)(ii) - Rs. 1,21,36,406. 5.1 In the grounds raised (supra), Revenue assails the action of the learned CIT (Appeals) in deleting the disallowance of Rs. 1,21,36,406 made by the Assessing Officer under Section 14A r.w. Rule 8D(2)(ii). It is contended that learned CIT (Appeals) erred in a....